Fee for technical service in DTAA between India-China covers provision of service while Pak-China treatise talks about 'provision of rendering of services. Hence DTAA between India-China gives more comprehensive coverage to fee for technical service and service might get covered even if it is not rendered. Hence Chinese subsidiary of Indian company getting service cost plus 10% from Indian company for specialized services of market research and information on new developments in China with regard to technology/product/process upgrade etc., held taxable at gross amount including reimbursement of actual service cost following Timken India Limited (AAR No.617 of 2003). [2015] 62 taxmann.com 96 (AAR - New Delhi)